Prudential LINK Advisors Form ADV Part 2B Brochure Supplements

Transcription

1 LINK by Prudential Bass Lake Road Plymouth, MN PRU LINK ( ) Prudential LINK Advisors Form ADV Part 2B Brochure Supplements Prudential Customer Solutions LLC Bass Lake Road Plymouth, MN September 27, 2018 These Brochure Supplements provide information that supplements the Prudential Customer Solutions LLC ("PCS") Brochure. You should have received a copy of that Brochure. This document contains ADV Part 2B Brochure Supplements for Prudential LINK financial advisors who provide service and support to clients enrolled in PCS managed accounts. Please contact John Savoie at if you did not receive PCS's Brochure or if you have any questions about the contents of these supplements. Additional information about each Prudential LINK financial advisor is available on the SEC website at Prudential LINK is an umbrella marketing name for Prudential Customer Solutions LLC ( PCS ), Prudential Annuities Distributors, Inc. and various subsidiaries of The Prudential Insurance Company of America. Investment advisory products and services are made available through PCS, an SEC registered investment adviser. Prudential LINK and LINK by Prudential occasionally may be referred to as LINK. PCS is not a licensed insurance agency or broker. Life insurance and annuities are issued by The Prudential Insurance Company of America (sometimes referred to as PICA ), Pruco Life Insurance Company (except in New York, issued by Pruco Life Insurance Company of New Jersey), Newark, NJ (main office). Variable annuities are distributed by Prudential Annuities Distributors, Inc., Shelton, CT and sold by registered representatives of Pruco Securities, LLC ( Pruco ), member FINRA, SIPC. All are Prudential Financial companies and each is solely responsible for its own financial condition and contractual obligations. Prudential LINK financial representatives are licensed insurance agents and appointed to represent The Prudential Insurance Company of America and its affiliated insurers and are registered representatives of Pruco Prudential, Prudential LINK, the Prudential logo, the Rock symbol and Bring Your Challenges are service marks of Prudential Financial, Inc., and its related entities, registered in many jurisdictions worldwide.

2 Benjamin Goodrich Item 2 Educational Background and Business Experience Birth: 1990 Education: BA St. Cloud State University, St. Cloud, MN Business Background (past 5 years): Prudential 07/2018 to Present Investment Advisor Representative Mr. Goodrich joined Prudential as an Investment Advisor Representative in July Benjamin will support recommendations made through PCS s (Prudential Customer Solutions LLC) online system that aligns client s needs and goals with solutions. He joined a team of representatives providing financial solutions for clients through Prudential s LINK Platform. Eckberg Wealth Management 06/2017 to 07/2018 Associate Wealth Management Advisor Benjamin was an Associate Wealth Management Advisor who constructed comprehensive financial plans for prospective clients going through the holistic financial planning process. As part of his role, Benjamin would implement, monitor and trade client investment portfolios. Unemployment 03/2017 to 06/2017 Wealth Enhancement Group 10/2015 to 02/2017 Client Service Manager Mr. Goodrich was part of an advisory team providing service to clients with account inquiries, monitoring client accounts, preparing annual reviews, setting up appointments and implementing financial plans for prospective clients. US Bancorp 08/2013 to 10/2015 Investment Sales Support Representative Benjamin worked with a team of representatives providing sales support for all US Bancorp Advisors by providing marketing materials, systems support, and responding to account inquiries. Industry Designation: Description of Requirements: None N/A

3 Item 3 Disciplinary Information Benjamin Goodrich We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. We have no facts or events to report in response to this Item. Item 4 Other Business Activities If a Supervised Person is actively engaged in any other investment related business or occupation, we are required to disclose this fact and describe the business relationship, if any, between our advisory business and the other business, and if that creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. Also, if a supervised person receives compensation based on sales of securities or other investment products, we must make disclosures and explain resulting incentives. We have no information to report in response to this Item. Item 5 Additional Compensation If someone who is not our client provides an economic benefit to our supervised person for providing advisory services, we are required to describe the arrangement. Economic benefits include sales awards or other prizes or a bonus that is based at least in part on the number or amount of sales, client referrals or new accounts. We have no information to report in response to this Item. Item 6 Supervision Mr. Goodrich is subject to compliance with the written policies and procedures, standards of conduct, and general oversight of Prudential Customer Solutions. Benjamin s supervisor is responsible for managing the day to day activities of investment advisor representatives and assuring that Benjamin Goodrich adheres to the firm s standards. Benjamin Goodrich is directly supervised by John Savoie, Director of Investment Advisory Sales. John Savoie can be reached at

4 Charles Norris Item 2 Educational Background and Business Experience Birth: 1982 Education: MBA Northeastern University, Boston, MA Business Background (past 5 years): Prudential 11/2017 to Present Investment Advisor Representative Mr. Norris transitioned to an Investment Advisor Representative in November 2017 and is currently working towards completing his CFP designation this year. Chuck will support recommendations made through PCS s (Prudential Customer Solutions LLC) online system that aligns client s needs and goals with solutions. Prudential 12/2014 to 11/2017 Internal Wholesaler Chuck spent his first three years as an Internal Wholesaler supporting our Business General Agencies by delivering Prudential products and services to their customers. As part of this role he focused on advanced case design and planning through our life insurance platform. Ameriprise 11/2013 to 11/2014 Financial Advice Sales Consultant Mr. Norris provided Financial Planning assistance to Ameriprise Financial Group advisors and their clients. He focused on helping advisors transition their business to a more holistic based platform and educated them on the benefits of incorporating financial planning into their practices. Oppenheimer & Co Inc 05/2010 to 11/2013 Financial Advisor Mr. Norris worked with both individual and institutional accounts, focusing primarily on the municipal market in Minnesota for our Institutional accounts. He conducted holistic financial planning for our individual retail accounts across the country. Industry Designation: Description of Requirements: None N/A

5 Charles Norris Item 3 Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. We have no facts or events to report in response to this Item. Item 4 Other Business Activities If a supervised person is actively engaged in any other investment related business or occupation, we are required to disclose this fact and describe the business relationship, if any, between our advisory business and the other business, and if that creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. Also, if a supervised person receives compensation based on sales of securities or other investment products, we must make disclosures and explain resulting incentives. We have no information to report in response to this Item. Item 5 Additional Compensation If someone who is not our client provides an economic benefit to our supervised person for providing advisory services, we are required to describe the arrangement. Economic benefits include sales awards or other prizes or a bonus that is based at least in part on the number or amount of sales, client referrals or new accounts. We have no information to report in response to this Item. Item 6 Supervision Mr. Norris is subject to compliance with the written policies and procedures, standards of conduct, and general oversight of Prudential Customer Solutions. Charles s supervisor is responsible for managing the day to day activities of investment advisor representatives and assuring that Charles Norris adheres to the firm s standards. Charles Norris is directly supervised by John Savoie, Director of Investment Advisory Sales. John Savoie can be reached at

6 Daniel Buchholz Item 2 Educational Background and Business Experience Birth: 1986 Education: BA, University of Minnesota, Twin Cities Business Background (past 5 years): Prudential 07/2018 to Present Investment Advisor Representative Mr. Buchholz transitioned to an Investment Advisor Representative in July Daniel will support recommendations made through PCS s (Prudential Customer Solutions LLC) online system that aligns client s needs and goals with solutions. Prudential 10/2013 to 07/2018 Financial Advisor For four years, Daniel was a financial advisor within the Prudential Advisors division. In that role, he was responsible for helping clients achieve their financial goals, including protection through life insurance, asset growth via investments, and retirement readiness through financial planning. Treasure Island Resort & Casino 6/2009 to 12/2013 Poker Room Supervisor Mr. Buchholz was a poker room dealer and supervisor. In that role, he monitored the daily operations of the poker room, ensured gaming protocols were meeting company standards, and provided a friendly environment for guests and patrons. Industry Designation: Description of Requirements: Retirement Income Certified Professional (RICP) To be a holder of the right to use the Retirement Income Certified Professional designation (RICP), one must complete three college level courses and complete a twohour exam for each respective course. Item 3 Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. We have no facts or events to report in response to this Item.

7 Item 4 Other Business Activities Daniel Buchholz If a supervised person is actively engaged in any other investment related business or occupation, we are required to disclose this fact and describe the business relationship, if any, between our advisory business and the other business, and if that creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. Also, if a supervised person receives compensation based on sales of securities or other investment products, we must make disclosures and explain resulting incentives. We have no information to report in response to this Item. Item 5 Additional Compensation If someone who is not our client provides an economic benefit to our supervised person for providing advisory services, we are required to describe the arrangement. Economic benefits include sales awards or other prizes or a bonus that is based at least in part on the number or amount of sales, client referrals or new accounts. We have no information to report in response to this Item. Item 6 Supervision Mr. Buchholz is subject to compliance with the written policies and procedures, standards of conduct, and general oversight of Prudential Customer Solutions. Daniel s supervisor is responsible for managing the day to day activities of investment advisor representatives and assuring that Daniel Buchholz adheres to the firm s standards. Daniel Buchholz is directly supervised by John Savoie, Director of Investment Advisory Sales. John Savoie can be reached at

8 Daniel Kakach Item 2 Educational Background and Business Experience Birth: 1975 Education: BA Bethel University, Arden Hills, MN Business Background (past 5 years): Prudential 07/2018 to Present Investment Advisor Representative Mr. Kakach joined Prudential as an Investment Advisor Representative in July Daniel will support recommendations made through PCS s (Prudential Customer Solutions LLC) online system that aligns client s needs and goals with solutions. He enjoys helping clients develop a personalized financial roadmap to help them achieve what matters most in their financial journey. Ameriprise Financial 11/2010 to 07/2018 Wealth Management Specialist Managed Accounts and Capital Markets Internal Wholesaler Daniel worked closely with internal and external product partners to help promote and educate advisors on fee based and managed account product offerings. Daniel partnered with Wealth Management product teams to help promote advisor awareness and knowledge of Structured Products, Alternative Investments and Syndicate offerings. He consulted with advisors on product features and benefits, proposals, competitive analysis, product positioning and sales strategies. Industry Designation: Description of Requirements: None N/A Item 3 Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. We have no facts or events to report in response to this Item.

9 Item 4 Other Business Activities Daniel Kakach If a Supervised Person is actively engaged in any other investment related business or occupation, we are required to disclose this fact and describe the business relationship, if any, between our advisory business and the other business, and if that creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. Also, if a supervised person receives compensation based on sales of securities or other investment products, we must make disclosures and explain resulting incentives. We have no information to report in response to this Item. Item 5 Additional Compensation If someone who is not our client provides an economic benefit to our supervised person for providing advisory services, we are required to describe the arrangement. Economic benefits include sales awards or other prizes or a bonus that is based at least in part on the number or amount of sales, client referrals or new accounts. We have no information to report in response to this Item. Item 6 Supervision Mr. Kakach is subject to compliance with the written policies and procedures, standards of conduct, and general oversight of Prudential Customer Solutions. Daniel s supervisor is responsible for managing the day to day activities of investment advisor representatives and assuring that Daniel Kakach adheres to the firm s standards. Daniel Kakach is directly supervised by John Savoie, Director of Investment Advisory Sales. John Savoie can be reached at

10 James Brattensborg Item 2 Educational Background and Business Experience Birth: 1968 Education: BS St. John s University Business Background (past 5 years): Prudential 12/2017 to Present Investment Advisor Representative Mr. Brattensborg transitioned to an Investment Advisor Representative role in December of James will support recommendations made through PCS s (Prudential Customer Solutions LLC) online system that aligns client s needs and goals with solutions. Prudential 06/2014 to 12/2017 Life Insurance Internal Wholesaler James spent his first three and a half years at Prudential as an Internal Wholesaler supporting key financial institutions and Prudential Advisors in delivering Prudential products and services to their customers. Small Business Insurance Agency 10/2013 to 06/2014 Life Insurance Internal Wholesaler Mr. Brattensborg was a Life Insurance Internal Wholesaler supporting the Wells Fargo Advisors channels. In this role he provided education, guidance and advanced case design on the many uses of life insurance including estate planning, buy/sell agreements, key person insurance, executive bonus plans, loan rescues, chronic illness situations, and max funding scenarios. Country Financial 02/2012 to 08/2013 Financial Representative James provided holistic investment and insurance solutions for clients based upon a thorough needs analysis review. Mr. Brattensborg was instrumental in providing clients with dynamic needs based solutions and ultimately helping them reach their financial goals. Industry Designation: Description of Requirements: None N/A

11 James Brattensborg Item 3 Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each Supervised Person providing investment advice. We have no facts or events to report in response to this Item. Item 4 Other Business Activities If a Supervised Person is actively engaged in any other investment related business or occupation, we are required to disclose this fact and describe the business relationship, if any, between our advisory business and the other business, and if that creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. Also, if a supervised person receives compensation based on sales of securities or other investment products, we must make disclosures and explain resulting incentives. We have no information to report in response to this Item. Item 5 Additional Compensation If someone who is not our client provides an economic benefit to our Supervised Person for providing advisory services, we are required to describe the arrangement. Economic benefits include sales awards or other prizes or a bonus that is based at least in part on the number or amount of sales, client referrals or new accounts. We have no information to report in response to this Item. Item 6 Supervision Mr. Brattensborg is subject to compliance with the written policies and procedures, standards of conduct, and general oversight of Prudential Customer Solutions. James s supervisor is responsible for managing the day to day activities of investment adviser representatives and assuring that James Brattensborg adheres to the firm s standards. James Brattensborg is directly supervised by John Savoie, Director of Investment Advisory Sales. John Savoie can be reached at

12 John A. Lake Item 2 Educational Background and Business Experience Birth: 1964 Education: St. Thomas University; BA Business Background (past 5 years): Prudential 04/2018 to Present Investment Advisor Representative Mr. Lake transitioned to an Investment Advisor Representative role in April of John will support recommendations made through PCS s (Prudential Customer Solutions LLC) online system that aligns client s needs and goals with solutions. Burns Brothers Financial Group 06/2016 to 03/2018 Wealth Manager John A. Lake was a Wealth Manger providing financial clarity to individuals, business and nonprofit groups. He offered detailed insight with long term partnerships to give his clients greater success in achieving their respective goals. Lake Consulting Group 08/2014 to 06/2016 Business Consultant Mr. Lake consulted and coached on many aspects of the financial services industry while he worked with financial advisors to small independent broker dealers in the Midwest. His primary focus was strategic planning for broker dealers to mass affluent client acquisition, along with wealth management strategies and practice management for financial advisors. Palladiem 08/2012 to 08/2013 National Sales Director Head of Sales Mr. Lake implemented wholesaling strategies for start up money management firms. Industry Designation: Description of Requirements: None N/A

13 John A. Lake Item 3 Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each Supervised Person providing investment advice. We have no facts or events to report in response to this Item. Item 4 Other Business Activities If a Supervised Person is actively engaged in any other investment related business or occupation, we are required to disclose this fact and describe the business relationship, if any, between our advisory business and the other business, and if that creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. Also, if a supervised person receives compensation based on sales of securities or other investment products, we must make disclosures and explain resulting incentives. We have no information to report in response to this Item. Item 5 Additional Compensation If someone who is not our client provides an economic benefit to our Supervised Person for providing advisory services, we are required to describe the arrangement. Economic benefits include sales awards or other prizes or a bonus that is based at least in part on the number or amount of sales, client referrals or new accounts. We have no information to report in response to this Item. Item 6 Supervision Mr. Lake is subject to compliance with the written policies and procedures, standards of conduct, and general oversight of Prudential Customer Solutions. John s supervisor is responsible for managing the day to day activities of investment adviser representatives and assuring that John A. Lake adheres to the firm s standards. John A. Lake is directly supervised by John Savoie, Director of Investment Advisory Sales. John Savoie can be reached at

14 John Savoie Item 2 Educational Background and Business Experience Birth: 1968 Education: B.A. University of St. Thomas Business Background (past 5 years): Prudential 01/2018 to Present Director, Investment Advisory Sales Mr. Savoie is a Director, Investment Advisory Sales for Prudential Customer Solutions LLC. In this role, Mr. Savoie will support recommendations made through the PCS online system that aligns client s needs and goals with solutions. Associated Benefits and Risk Consulting 11/2011 to 01/2018 Director, Advanced Planning John developed detailed insurance solutions for prospects and clients. He helped Advisors develop financial plans for their clients. Industry Designation: Description of Requirements: None N/A Item 3 Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each Supervised Person providing investment advice. We have no facts or events to report in response to this Item. Item 4 Other Business Activities If a supervised person is actively engaged in any other investment related business or occupation, we are required to disclose this fact and describe the business relationship, if any, between our advisory business and the other business, and if that creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. Also, if a supervised person receives compensation based on sales of securities or other investment products, we must make disclosures and explain resulting incentives. We have no information to report in response to this Item.

15 John Savoie Item 5 Additional Compensation If someone who is not our client provides an economic benefit to our Supervised Person for providing advisory services, we are required to describe the arrangement. Economic benefits include sales awards or other prizes or a bonus that is based at least in part on the number or amount of sales, client referrals or new accounts. We have no information to report in response to this item. Item 6 Supervision Mr. Savoie is subject to compliance with the written policies and procedures, standards of conduct, and general oversight of Prudential Customer Solutions. John s supervisor is responsible for managing the day to day activities of investment advisor representatives and assuring that John Savoie adheres to the firm s standards. John Savoie is directly supervised by Matthew Hudnut, VP Advisor & Broker Dealer Sales, Service. Matthew Hudnut can be reached at

16 Lori Reiman Item 2 Educational Background and Business Experience Birth: 1969 Education: BA University of Minnesota, Minneapolis, MN Business Background (past 5 years): Prudential 07/2018 to Present Investment Advisor Representative Ms. Reiman joined Prudential as an Investment Advisor Representative in July Lori will support recommendations made through PCS s (Prudential Customer Solutions LLC) online system that aligns client s needs and goals with solutions. Lori will provide needs based guidance to clients by serving as the client s trusted advisor via an online platform. Unemployment 06/2018 to 07/2018 Ameriprise 04/2017 to 05/2018 Associate Advisor Ms. Reiman provided overall administrative, operations support, and guidance to a team of financial advisors. She provided client relationship support through managing, gathering and analyzing client data, helping prepare preliminary financial plans, and other client deliverables. Lori s main objective was to provide exemplary client focused service, as well as, to assist financial advisors with the financial planning process. Thrivent Financial 05/2015 to 04/2017 Financial Representative As a financial representative, Ms. Reiman actively engaged clients in providing financial solutions unique to their needs and goals. Prior to this role, Lori held client centric positions as a support administrator to a financial representative. Target Corporation 09/2012 to 05/2015 Human Resources Team Member During Lori s tenure at Target, she held several positions leading up to her human resources team member position. In that role, Ms. Reiman was instrumental in onboarding new team members to Target from initial interviews to orientation, and actively served as the subject matter expert for new employees.

17 Industry Designation: Description of Requirements: Lori Reiman None N/A Item 3 Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. We have no facts or events to report in response to this Item. Item 4 Other Business Activities If a Supervised Person is actively engaged in any other investment related business or occupation, we are required to disclose this fact and describe the business relationship, if any, between our advisory business and the other business, and if that creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. Also, if a supervised person receives compensation based on sales of securities or other investment products, we must make disclosures and explain resulting incentives. We have no information to report in response to this Item. Item 5 Additional Compensation If someone who is not our client provides an economic benefit to our Supervised Person for providing advisory services, we are required to describe the arrangement. Economic benefits include sales awards or other prizes or a bonus that is based at least in part on the number or amount of sales, client referrals or new accounts. We have no information to report in response to this Item. Item 6 Supervision Ms. Reiman is subject to compliance with the written policies and procedures, standards of conduct, and general oversight of Prudential Customer Solutions. Lori s supervisor is responsible for managing the day to day activities of investment advisor representatives and assuring that Lori Reiman adheres to the firm s standards. Lori Reiman is directly supervised by John Savoie, Director of Investment Advisory Sales. John Savoie can be reached at

18 Neal Robinson Item 2 Educational Background and Business Experience Birth: 1990 Education: B.A. The College of St. Scholastica, Duluth, MN Business Background (past 5 years): Prudential 01/2018 to Present Investment Advisor Representative Mr. Robinson is an Investment Advisor Representative for Prudential Customer Solutions LLC. In this role, Neal will support recommendations made through the PCS online system that aligns client s needs and goals with solutions. Merrill Lynch 04/2017 to 01/2018 Financial Advisor Mr. Robinson met with clients and prospects to review their financial goals. He reviewed and implemented customized financial plans and used financial planning software extensively. Neal partnered with trust services to develop and expand relationships with high net worth clients. Edward Jones 01/2014 to 04/2017 Financial Advisor Neal created comprehensive financial plans for clients to help them achieve retirement and investment goals through tailored financial solutions. He used individual stocks, mutual funds, ETFs, UITs, life insurance, and annuities to help clients reach their financial goals. Mr. Robinson Independently managed over $17 million assets under management. PlaneTechs 01/2013 to 12/2013 Project Administrator Neal oversaw the day to day operations of over 60 aircraft mechanics. Mr. Robinson monitored the weekly payroll, recruited mechanics from throughout the U.S., and built and sustained over 70% market share of the labor work force. Industry Designation: Description of Requirements: None N/A

19 Neal Robinson Item 3 Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each Supervised Person providing investment advice. We have no facts or events to report in response to this Item. Item 4 Other Business Activities If a supervised person is actively engaged in any other investment related business or occupation, we are required to disclose this fact and describe the business relationship, if any, between our advisory business and the other business, and if that creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. Also, if a supervised person receives compensation based on sales of securities or other investment products, we must make disclosures and explain resulting incentives. We have no information to report in response to this Item. Item 5 Additional Compensation If someone who is not our client provides an economic benefit to our Supervised Person for providing advisory services, we are required to describe the arrangement. Economic benefits include sales awards or other prizes or a bonus that is based at least in part on the number or amount of sales, client referrals or new accounts. We have no information to report in response to this item. Item 6 Supervision Mr. Robinson is subject to compliance with the written policies and procedures, standards of conduct, and general oversight of Prudential Customer Solutions. Neal s supervisor is responsible for managing the day to day activities of investment advisor representatives and assuring that Neal Robinson adheres to the firm s standards. Neal Robinson is directly supervised by John Savoie, Director of Investment Advisory Sales. John Savoie can be reached at

20 Sean Shepherd Item 2 Educational Background and Business Experience Birth: 1979 Education: High School Diploma Business Background (past 5 years): Prudential 11/2017 to Present Investment Advisor Representative Mr. Shepherd is an Investment Advisor Representative for Prudential Customer Solutions LLC. In this role, Mr. Shepherd will support recommendations made through PCS s online system that aligns client s needs and goals with solutions. Ameriprise Financial 09/2010 to 06/2017 Wealth Management Consultant Mr. Shepherd was a Wealth Management Consultant at Ameriprise Financial, providing clients and Financial Advisors recommendations on Managed Accounts and Complex Capital Markets Solutions. Industry Designations: Description of Requirements: None N/A Item 3 Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. We have no facts or events to report in response to this Item. Item 4 Other Business Activities If a supervised person is actively engaged in any other investment related business or occupation, we are required to disclose this fact and describe the business relationship, if any, between our advisory business and the other business, and if that creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. Also, if a supervised person receives compensation based on sales of securities or other investment products, we must make disclosures and explain resulting incentives. We have no information to report in response to this Item.

21 Sean Shepherd Item 5 Additional Compensation If someone who is not our client provides an economic benefit to our supervised person for providing advisory services, we are required to describe the arrangement. Economic benefits include sales awards or other prizes or a bonus that is based at least in part on the number or amount of sales, client referrals or new accounts. We have no information to report in response to this Item. Item 6 Supervision Mr. Shepherd is subject to compliance with the written policies and procedures, standards of conduct, and general oversight of Prudential Customer Solutions. Sean s supervisor is responsible for managing the day to day activities of investment advisor representatives and assuring that Sean Shepherd adheres to the firm s standards. Sean Shepherd is directly supervised by John Savoie, Director of Investment Advisory Sales. John Savoie can be reached at